1 U.S. CONSUMER PRODUC T SAFETY COMMISSION

LOG OF TELEPHONE CAL L

SUBJECT: Firm’s request for an exception from the CPSIA section 101 lead content limit for children’s products of 100 ppm lead; CPSC staff posed general and specific questions; firm provided an swers and explanations about the topics raised

DATE OF TELEPHONE CALL: 10/21/2011

LOG ENTRY SOURCE: Kristina Hatlelid

LOCATION: CPSC HQ, Bethesda, MD

CPSC PARTICIPANT(S): Kris tina Hatlelid , Directorate for Health Sciences, and

T homas Caton , Directora te for Engineering Sciences

NON

- CPSC PARTICIPANT(S): Jane Ertl and Bob Willits of Joseph L. Ertl, Inc.

, Scale Models and Dyersville Die Cast

SUMMARY OF TELEPHONE CALL:

Discussion of aluminum alloys A380 and A413 .1

• A 380 .1 is the most universally used al uminum alloy

• Most used alloy in Dyersville Die Cast is A413 .1

• A413 .1 is readily available

• A413 .1 is more corrosion resistan t than A380 .1

• A413 .1 costs about 6

- 10 cents per pound more than A 380 .1 ; this means an increased cost of several dollars for the end p roduct

Lead in A380 .1

• A 380 .1 lead content is about 600 ppm (National Association of Die Casting spec
for A380 .1 is 600 ppm lead ) ; it is possible when working closely with a supplier,

to obtain A 380 .1 with about 300 ppm lead with a small up

- charge; conce ntration is right near 300 ppm lead

• Firm is comfortable with a 300 ppm lead limit for A 380 .1

Lead in A413 .1

• A 413 .1 is guaranteed no more than 200 ppm; average about 125 ppm

• In addition, other customers require no more than 200 ppm lead for A413 .1 , and

som e customers test every shipment

• Firm is very comfortable with a 200 ppm lead limit for A 413 .1 Suppliers

• Firm w ork s with three primary suppliers of aluminum, and contacted others

• Have not found a supply of casting alloy with less than 100 ppm lead2

• Suppliers indicate A 413 .1 may occasionally be found less than 100 ppm, but this

is “accidental”

• A 380 .1 may be found less than 300 ppm; th is is “accidental”, but by working closely with suppliers, the firm is able to purchase A 380 .1 with this lead level

• Explained t hat there is difference between alloys that can be used for die casting,

such as A380 .1 and A413 .1 , and alloys that can be used with sand casting; alloys for sand casting cannot be used for die casting

Differences between A380 .1 and A413 .1

• Higher silicon in A 413 .1 tends to improve flow during casting

• A 413 .1 is “stickier”

• Firm uses A 413.1, lower in copper, which provides better corrosion resistance compared to other alloys

Other

• When firm changes from one alloy to another in production, a time

- consuming

c lean out step is required before moving to next metal ; if different alloys are not used, no clean out is needed

• Currently, toy production using A 413 .1

• Process for checking lead content during production: small disk is poured, cooled, and then analyzed for lead content with the in

- house spectrometer (not an XRF; uses an electrode and light emission)

• Firm is 95% non

- toy, but toy product line is very important to the company

Supplies

• 132,000 pounds is a “ heat ”; i.e., a single instance of alloy production

• Firm purchases 44,000 pounds (a truckload) at a time

• Purchase s 6

- 7 million pounds per year for all needs

Possible use of other materials

• Zinc

o The main issue with zinc is the weight; the final product would be very heavy and difficult for a child to use

o Also, existing tooling would become obsolete, would have to be changed; not clear that zinc die casting can be done with the large parts of the products

o Big cost difference o n a product basis: the price for zinc alloy vs. aluminum alloy is not that different (a bout $1.20 per pound for aluminum; about $1.10 per pound for zinc), but because zinc is heavier, many more pounds of zinc are required per product

• Steel

o Use of steel would be stamping instead of die casting, resulting in a completely different product and using a completely different manufacturing process

• Magnesium3 o Magnesium can also be used in die casting, but it requires different equipment and a different process

o It has hazards (fire), and also environmental impacts not seen with

aluminum

o Unsure about l ead content

o Overall, this material is not a practical solution